Annex N - Emergency Response Monitoring, Sampling and Analysis Plan

HD Release, Umatilla Chemical Depot, OR

  1. The proposed schedule follows:
    2. Activity Estimated Start Date Estimated Completion Date Comments
    SSSP Review/Approval     TBD.
    Mobilize to / Demobilize from Site H + 8 hours H + 5 days State and regional resources only; local resources will be on-site immediately.
    Sample Collection H + 12 hours H + 5 days Confirmation of non-contamination only, Responder Monitoring and Evacuation Monitoring will occur immediately.
    Laboratory Sample Receipt H + 36 hours H + 5 days Assumes rapid sample delivery to off-site labs. Responder Monitoring and Evacuation Monitoring will give immediate results. National Guard, OR DOH and US EPA will begin confirmation of non-contamination at H + 12.
    Laboratory Analysis H + 2 days H + 7 days Off-site analysis only. National Guard, OR DOH and US EPA will report results immediately.
    Data Validation H + 3 days H + 7 days Off-site analysis only.

  2. Historical and Background Information

    3. Mustard agent, bis (2-chloroethyl) sulfide, is a chemical warfare agent that has been stored for six decades at the Umatilla Chemical Depot (UMCD). Destruction of this agent is currently being performed on site by incineration. An in-place monitoring program ensures that concentrations of agent leaving the site pose little risk to nearby inhabitants.

    Should there be a release of agent from the site, through either a failure of the incineration process, or through release of stored agent awaiting incineration, affected communities will respond by sheltering in place during the initial transit of the plume, followed by evacuation. An emergency response sampling plan will help the communities determine when sheltering-in-place can transition to evacuation, and in verifying the area needing evacuation.

    Re-occupancy of evacuated areas will occur later in the response; it is not the intent of this sampling plan to address the sampling and analytical requirements of the re-occupancy period.

    Assumptions of this plan include:

    • The results of plume modeling will be the primary information available during the early phases of the response.
    • Early in the response, UMCD will “ground truth” the plume by physically determining if the source term entered into the plume model was appropriate.
    • UMCD will release 1-2 Real Time Analytical Platforms (RTAPs) to assist the community in the emergency response phase.
    • These RTAPs will provide monitoring for emergency responders operating near or within the projected plume.
    • Additionally, the data collected by these RTAPs will be incorporated into the ongoing assessment of contamination.
    • Environmental sampling teams from OR DEQ, OR DOH, USEPA, and DoD will arrive later in the emergency response phase and verify the extent of non-contamination.
    • In the emergency response phase, only two laboratories, the Southwest Research Insitute (SwRI, and the Midwest Research Institute (MwRI), will be available to perform off-site analysis.

  3. Conceptual Site Model

    4. Contaminants: Mustard agent and its breakdown products.

    Transport Mechanisms: Vapor phase transport by wind and/or partially combusted product carried by wind as a particulate.

    Receptors: People and animals downwind of the plume at the time of the release and/or that enter the area of the plume’s transit and encounter vapor/particulate deposited or adsorbed on surfaces. Potentially affected communities include Umatilla, Irrigon, Boardman, Stanfield, Echo and Hermiston.

  4. Decision Statements

    5. The decisions to be made from this investigation are to:

    1. Determine if ventilation should begin.
    2. Determine if populations sheltering-in-place can safely evacuate.
    3. Determine if populations can be evacuated along a route.
    4. Verify that areas outside the projected plume have not been contaminated by the release.

  5. Action Guidelines

    6. The decision to begin ventilation of structures will be informed by the plume model and subsequent “ground truthing” of the model, and is therefore referenced here. The Action Guidelines for Decision 1, Ventilation, will be a recommendation from the MAC to the IC based upon the plume projection and additional information from the depot. Details on this process are described in the Incident Response Action Plan for the Greater Umatilla Community (http://www.csepp.org/content/Annex-f-ventilationextraction).

    The Action Guideline for Decision 2, Evacuation, and Decision 3, Evacuation Routes, is one hundredth of the 60 minute AEGL 1 for HD, which is 0.00067 mg/m3. Since this value is below the detection limit of the RTAPP, a non-detect result on an RTAPP after shelter ventilation has been approved will indicate safe conditions for evacuation. The assumption behind this Action Level is that populations will be safely evacuated from shelter-in-place to unaffected areas with 1 hour of transit time. Note that this value does not assume evacuation within 60 minutes of plume release; instead it addresses the likely health consequences of a 60 minute exposure during evacuation. This AEGL is divided by 100 to provide an additional protection factor to exposed populations.

    The Action Guideline for Decision 4, Verification of Non-Contamination, in air is 0.003 mg/m3 of HD. This is the detection limit of the RTAP and the OR DOH mobile laboratory; if agent is undetectable and plume projections have not projected agent in the area, it will be assumed that these areas remain safe for occupancy.

    The Action Level for Decision 4 in soil is 0.01 mg/kg. This value is a CHPPM-derived value based on the assumptions and calculations of the US EPA Region 9 Preliminary Remediation Goals. The SwRI has a limit of detection of HD in soil of 0.005mg/kg. If values /are below this PRG equivalent, and the plume was not projected to enter the area, the area is assumed to remain safe for occupancy.

    The Action Level for Decision 4 in wipes is 0.5 µg/100cm2 (USACHPPM TG 312, Risk Assessment Methods for Surface Wipe Data, with cancer risk 1x10-6). This value is below the routine method detection limit of the analytical systems used by off-site labs (>1µg/100 cm2), or OR DOH, ORNG, or USEPA field labs (MDLs undetermined) If HD and its breakdown products are undetectable on wipes, and the plume was not projected to enter the area, the area is assumed to remain safe for occupancy.

  6. Decision Areas

    7. Four generic decision areas can be described:

    1. Populations sheltering in place preparing to ventilate.
    2. Proximity to exits from shelter-in-place locations.
    3. Evacuation routes from shelters.
    4. Important sites adjacent to, but outside the plume projection, including schools, neighborhoods, hospitals, businesses, public buildings, fire and police services, and transportation corridors. A list of important critical infrastructure in the community in located in Appendix 2 to Annex N of the Incident Response Action Plan for the Greater Umatilla Community (http://www.csepp.org/content/appendix-2-prioritized-post-event-sampling-sites). Sampling priorities will be determined by the Incident Commander

  7. The Decision Rules

    8. The following statement(s) describe the decision rules to apply to this investigation:

    Plume data and additional information from UMCD will inform the IC’s decision to begin ventilation.

    If airborne concentrations of mustard agent are less than 0.003 mg/m3, and ventilation of shelters has begun, emergency evacuation from shelter-in-place can be performed.

    If airborne concentrations of mustard agent are less than 0.003 mg/m3 on a route of evacuation, evacuees can use the route. At least one sample will be collected on the following routes, if all or part is within the plume projection:

    • I-84 from its junction with Hwy 730 east to Exit 189 (Stanfield Exit)
      • From I-82 east to exit 182 (Hwy 207)
      • From exit 182 east to exit 189 (Stanfield exit)
    • Hwy 395 from Columbia River south to its junction with I-84
      • From Main Street in Hermiston south to I-84
      • From Columbia River south to Punkin Ctr. Road in Hermiston
      • From Punkin Ctr. Road south to Main Street in Hermiston
    • County Road 1300 (Thielson Road) from I-84 south through Echo and continuing southeast on Reith Road toward Pendleton to a point approximately 2 miles southeast of Echo
    • Hwy 207 from Punkin Ctr Road southwest to a point approximately 2 miles south of I-84
      • From I-84 north to 11th and Elm in Hermiston
      • From 395 in Hermiston east and northeast to Punkin Center Road
      • From 11th and Elm in Hermiston, north on 11th and east on Elm to Hwy 395
    • Hwy 730 from its junction with Hwy 207 (Diagonal Road) west to its junction with I-84
      • From Hwy 207 west to Hwy 395 (Diagonal Road)
      • From Powerline Road west of Umatilla west to I-84
      • From Hwy 395 west to Powerline Road east of Umatilla
    • I-82 from the Columbia River south to its junction with I-84

    Sampling is most informative if performed in depressions or urban areas.

    If airborne concentrations of mustard agent are less than 0.003 mg/m3, or surface wipe measurements have undetectable levels of HD, or if soil concentrations of HD are less than 0.01 mg/kg, and the area is projected to be outside of the hazard plume, an area is confirmed to be safe for occupancy

    * Additionally, any responder team in the exclusion zone with an AP2C reading above background will leave the exclusion zone immediately.

  8. Information Needed for the Decision Rules

    9. The following inputs to the decision are necessary to interpret the analytical results:

    Projected areal extent of the plume.

    Contaminant concentrations in the air, soil and surfaces.

  9. Information Inputs and the Decision Rules

    10. Decision Area 1 - Populations Sheltering in Place. The decision to begin ventilation will be made in accordance with the procedure outlined in the ER plan. The plume projection and subsequent “ground truth” of the plume by UMCD will be key information inputs.

    Decision Area 2 – Proximity to shelter-in-place exits. This is near real-time air analysis performed by UMCD RTAP units. At least one measurement should be performed outside public shelters. The IC may or may not decide that measurements outside private shelters are practical or achievable. The ideal location for such a measurement is on the pathway between the shelter exit and the evacuation vehicle. Because shelters may produce eddies that concentrate agent, measurements close to the shelter are preferable.

    Decision Area 3 – Evacuation Routes. This is near real-time air analysis performed by UMCD RTAP units.

    Decision Area 4 – Verification that important sites have not been contaminated.
    This is sampling that will be performed in one of three media:
    Air – RTAPs or OR DOH will collect air samples in proximity to the site of interest, or,
    Soil – A 4 oz jar of soil with 10 gm of soil will be collected from an unvegetated surface and analyzed off-site for HD and HD breakdown products. Maximize recovery from surface and near surface soil, or
    Wipe – A 100 cm2 wipe wetted with dichloromethane will be collected from clean, non-porous surfaces near the site of interest. The top surfaces of parked vehicles which have not moved since the incident are ideal samples.
    It is recommended that verification sampling for each site include 3 samples that involve some combination of the above media (i.e., 3 air samples, or 2 wipe and one air sample, or one air sample, one soil sample and one wipe sample, etc.)

  10. Special Sampling or Analysis Directions

    11. Wipes will be wetted with dichloromethane and wiped over a 100 square centimeter surface (ideally non-porous). Note that dichloromethane (synonyms: methylene chloride, methylene dichloride) is itself toxic, and gloves must be worn during use.

  11. Method Requirements

    12. The laboratories must follow its approved SOP or request approval and document any necessary modifications.

  12. Sample Collection Information

    13. The applicable sample collection Standard Operating Procedures (SOPs) or methods will be followed and include:
    Agency Field Activity Logbook SOP
    Agency Sample Packaging and Shipping SOP
    Agency Sampling Equipment Decontamination SOP
    US EPA Sample Control Form
    US EPA Sample Processing and Preparation SOG
    US EPA Sampling Data Collection and Quality Assurance Protocols SOG
    UMCD RTAP SOG and QA SOG
    OR DOH Instrument Operating SOGs
    ORNG Instrument Operating SOGs
    EPA Equipment Operating Guides and Quick Start Guides or Agency Equivalent
    EPA Method TO-10A
    Instrument SOPs _AP2C – Manufacturer’s directions______________
    Other SOPs_US EPA ERT SOP 2011 and 2012 with Region 10 Addendums_____________

    The format for sample number identification is summarized in Table 1. Sample collection and analysis information is summarized in Table 2.

    Table 1
    SAMPLE CODING
    Project Name _________ UMCD ER ____________________________ Site ID: ___________
    SAMPLE NUMBER (1)
    Digits Description Code (Example)
    1,2,3,4 Year and Month Code YYMM (0907)
    5,6,7,8 Consecutive Sample Number
    (grouped by SA as appropriate)    		 0501 - First sample of SA
    SAMPLE NAME / LOCATION ID (2)
    (Optional)
    1,2 Sampling Area AM – Air Monitoring performed by responders.
    EV – Evacuation measurement with RTAP performed by UMCD
    CF – Confirmatory Sampling
    3,4 Consecutive Sample Number 01 – First sample of DA.
    5,6 Matrix Code SO - Soil
    WP – Wipe
    ST – Sorbent Tube (RTAP)

    Notes:
    (1) The Sample Number is a unique, 8-digit number assigned to each sample.
    (2) The Sample Name or Location ID is an optional identifier that can be used to further describe each sample or sample location.

    Table 2. Information Collection
    Decision Area Matrix Sampling Pattern Sample Type Number of Field Samples Analyte or Parameter Method Number Action Level Method Quantitation Limit Sample Container Preservative Other Equipment Hold Time Turn Around Time Field QC
    1. Ventilation NA NA NA NA NA NA Determination by IC NA NA NA NA NA NA NA
    2, 3 Evacuation from Shelter-In-Place and Evacuation Routes Air by RTAP Target-ed Grab or near-real time Assumed rate of 2 per hour per RTAP HD UMCD SOP 0.00067 mg/m3 0.003 mg/m3 Tenax, Haye Sep D Pre-concentrator tubes (ACAMS, MINICAMS) Tenax, Chromosorb 106 sorbent tubes (DAAMS) NA NA Not applicable 3 minutes to 24 hours depending upon method and collection time. Per UMCD SOP
    4-Verification of non-Contamination Air by RTAP, OR DOH, Poly-urethane Filter (PUF) / Soil / Wipe Targeted Grab Sampling teams will be assumed to collect 20-30 samples per day per team. HD and HD breakdown products UMCD SOP (Air) OR DOH SOP (Air) US EPA SOP (Air/Soil/Wipe) OR NG SOP (Soil/Wipe) SwRI and MwRI SOG (Soil and Wipe) 0.003 mg/m3 (air) or 0.01 mg/kg (Soil) or MDL (Wipe)* 0.003 mg/m3 (air) or 0.005 mg/kg (soil) or >1 µg/ 100cm2 (wipe) 1-4 oz jar with 10 gm soil or 1 non-gauze wipe stored in conical vial or PUF tube. < 6o C for all Dichloromethane, wipes, vials, jars, ice, shipping containers 7 days 3 minutes (OR DOH air) 4 hours (wipes by OR NG, USEPA)48 hours (wipes, soil, PUF by MwRI, SwRI) 1 Blank for each matrix per 20 samples. 1 Matrix Spike and 1 Matrix Spike Duplicate per every 20 soil and wipe samples.

    *Method Detection Limits (MDLs) are assumed to be above 1.0 µg/100 cm2.